Modern Slavery Act 2026

POLICY STATEMENT

Modern Slavery Policy Statement

Overview

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps Mountjoy takes, and continues to take, to help prevent modern slavery and human trafficking in our business and supply chains.

Our organisation structure, business and supply chains

Mountjoy is a UK-based organisation providing property maintenance, construction and related services to public and private sector clients across Central South of England. Our operations include directly employed staff as well as subcontractors, agency labour and specialist suppliers engaged to deliver works safely on time and to specification.

Our supply chains include (among other things) materials and products (e.g., building materials, tools and equipment), labour providers (including subcontractors and agencies), professional services, logistics and waste services, and business support services. We expect all suppliers and business partners to share our commitment to preventing modern slavery and human trafficking.

Our policies in relation to slavery and human trafficking

Modern slavery is a crime and a violation of fundamental human rights. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking, all of which involve the deprivation of a person’s liberty to exploit them for personal or commercial gain.

Mountjoy has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to help ensure modern slavery is not taking place anywhere in our business or supply chains.

This commitment is supported by our internal policies and processes, which include recruitment and onboarding controls; supplier onboarding and contract terms; health and safety requirements; code of conduct/ethics standards; and confidential reporting/whistleblowing arrangements for employees and workers.

These expectations apply to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, subcontractors, seconded workers, contractors, external consultants, third-party representatives and business partners.

Due diligence processes

We take a risk-based approach to due diligence in our business and supply chains. Our processes are designed to identify, prevent and mitigate modern slavery and human trafficking risks, and to support effective remediation where concerns are identified.

  • Supplier onboarding and approval: proportionate checks before engagement, including consideration of the supplier’s own modern slavery policies/statement and controls.
  • Contractual requirements: modern slavery compliance obligations in supplier and subcontractor terms, including rights to request information and to take action for non-compliance.
  • Recruitment controls: processes intended to ensure workers are recruited lawfully, with appropriate right-to-work checks and without unfair fees or coercion.
  • Ongoing monitoring: periodic reviews of higher-risk suppliers and labour providers, and escalation routes for concerns.
  • Reporting and investigation: mechanisms for raising concerns confidentially and procedures for investigation and response.

 Risk assessment and risk management

We recognise that modern slavery risks can arise in many sectors. Within our business and supply chains, the risk of modern slavery and human trafficking is generally more likely to arise where there is the use of temporary or agency labour, subcontracting chains, low-skilled workforces and short-notice labour demands.

Steps we take to assess and manage these risks include:

  • Prioritising due diligence for labour providers and subcontractors operating on our sites or delivering services on our behalf;
  • Set expectations on fair treatment of workers, including wages, working hours, freedom of movement and retention of identity documents;
  • Encouraging transparency in subcontracting (including visibility of lower-tier subcontractors where applicable);
  • Spotting and escalating red flags (e.g., workers appearing controlled, unable to speak freely, inconsistent documentation, signs of debt bondage);
  • Remedial escalation and/or taking corrective action, up to and including termination of contracts, where serious concerns are identified;
  • Partnering with clients, suppliers and relevant stakeholders to address risk in a coordinated way where appropriate.

Effectiveness and performance indicators

We are committed to continuous improvement and to measuring the effectiveness of our approach. We monitor performance using indicators appropriate to the nature, scale and risk profile of our operations and supply chain.

  • Staff are trained in modern slavery awareness within 6 months of joining with refresher training periodically.
  • Number of modern slavery concerns raised and outcomes.
  • Number of suppliers reviewed for modern slavery controls during onboarding and periodic review.
  • Contract compliance checks, including inclusion of modern slavery obligations in supplier and subcontractor agreements.

Training and capacity building

We provide training and guidance to help staff understand modern slavery and human trafficking risks, identify potential warning signs and how to raise concerns. 

Training is delivered to all staff who join Mountjoy within 6 months proportionately based on their role and risk exposure (for example, enhanced guidance for procurement, contract management and operational/site-based roles).

We also communicate our expectations to suppliers and subcontractors where appropriate, and we encourage them to implement effective controls, provide training to their staff, and to notify us promptly if any modern slavery risks or incidents are identified.

Approval

This statement has been approved by the Board of Directors and is signed by a director on behalf of Mountjoy.

Name:  Simon Ingram

Title:  Managing Director
Date:  11th March 2026